as previous

I object to the proposed allocation of Policy PP29: Land East of School Road, Copford (Site ID: 10228). This allocation directly conflicts with the adopted Copford with Easthorpe Neighbourhood Plan (2023), specifically Policy CE1, which resists "large scale development" and urban sprawl. The cumulative impact with the nearby Hall Road development is significant. The site is unsustainable due to insufficient wastewater capacity, posing a pollution risk, and creates demonstrable highway safety risks. Furthermore, the development encroaches upon the Pits Wood Local Wildlife Site (LoWS), threatening sensitive biodiversity. The site is unsuitable for allocation. Please read attached accompanying Word document.

Dear Councillors,

I am writing to you as a resident of Copford to formally express my profound concern and objection to the proposed large-scale housing allocations in the Preferred Options Local Plan, specifically the combined development of approximately 2,100 new homes in the Copford and Marks Tey area (600 in Copford and 1,500 in Marks Tey).

While I understand the need for housing growth, the scale of this development is wholly unsupported by current infrastructure. The proposal will place an unacceptable and potentially dangerous burden on essential services and local safety.

I urge you to challenge these allocations on the basis of demonstrable infrastructure and sustainability deficits, supported by the following facts:

1. Education Capacity: An Immediate and Critical Deficit
The local primary school system is already at effective capacity and cannot absorb even the smallest expansion, let alone the proposed allocation.

Copford Church of England Primary School has a capacity of 210 pupils but currently enrolls 206. This leaves a functional surplus of only four places.

The planned new housing will create severe overcrowding. Based on the Essex County Council’s yield rate of 0.3 primary pupils per dwelling , the proposed 600 homes in Copford alone would generate demand for 180 new primary school places, leading to an unmitigated local deficit.

Furthermore, this scale of growth in Copford (300 homes in the Preferred Options Plan ) directly conflicts with the adopted Copford with Easthorpe Neighbourhood Plan, which explicitly set a limit of 120 new dwellings up to 2033, specifically due to infrastructure constraints.

2. Healthcare System Operating Beyond Safety Thresholds
Our acute and primary care services are already in crisis, and introducing an estimated 5,000 new residents will push them past a critical breaking point.

Colchester Hospital (ESNEFT) is already operating under severe strain, with reported bed occupancy rates reaching 97%. This significantly exceeds the clinically advised safety threshold of 85% , confirming that the hospital lacks any reserve capacity to handle a major population increase.

Primary Care access is similarly dire, with the patient-to-GP ratio in North East Essex standing at an alarming 2,543 patients for every GP. This chronic shortage forces patients to rely on the already overloaded acute care system.

3. Transport Failure and Public Safety Risk
The area’s reliance on the A12, coupled with the frequent closures for maintenance and incidents, guarantees systemic failure on local roads, creating a severe public safety threat.

When the A12 is closed (a routine occurrence), traffic is inevitably diverted onto local, unsuitable roads such as School Road and London Road. The additional vehicular traffic from 2,100 new, predominantly car-dependent homes will turn these diversion routes into daily gridlock, critically impacting emergency response times.

Road safety is already a known issue in the parish. Data from the Safer Essex Roads Partnership confirms that Copford is a targeted site for speed enforcement, with 76 offences detected in the area. Increased footfall, especially around the primary school, combined with pre-existing, high-risk speeding behaviour will create a demonstrably unacceptable rise in collision risk.

4. Environmental and Amenity Deficits
The plan undermines the sustainability goals and environmental value of our parish.

Pits Wood, a valued 12.5-acre Community Woodland and designated Local Wildlife Site (LWS) , will be directly threatened by the guaranteed increase in recreational disturbance, noise, and urban edge effects from adjacent large-scale development.

The lack of essential local services, specifically no local shop in Copford , means new residents will be forced to drive to Stanway or Colchester for basic amenities. This directly contributes to increased car dependency, congestion, and air pollution, conflicting with the city's stated environmental objectives.

In conclusion, the current Local Plan proposals for Copford and Marks Tey demonstrate a fundamental failure to link housing delivery with secured, funded, and phased infrastructure provision. I urge you to vote against the adoption of these housing allocations at the proposed scale.

I ask that you insist that the allocation for Copford be rejected, and that the Marks Tey allocation be made strictly conditional upon the prior physical completion and operational readiness of new schools, strategic highway improvements, and secured, proportional funding for ESNEFT.

The site may have detrimental effect on Gravelpit Wood Local; Wildlife Site. Should development go ahead the Wood should be protected by a significant buffer zone to protect its integrity and misuse. CNHS is also concerned at the proximity of the Roman River which has SSSI protection further downstream. The valley's biodiversity value should not be threatened by developments upstream that downgrade water quality. Attention is drawn to the 2019 publication 'Roman River Valley Living Landscape' a report by CNHS and Essex Wildlife Trust.

I am writing as Chair of Pits Wood Trust to object to the proposed housing development adjacent to Pits Wood, a valued community woodland with well-documented habitats for protected species, including nightingales and badgers. Nightingales are Schedule 1 protected and a Red List species, reliant on the woodland’s dense, low-disturbance scrub; nearby development would cause harmful noise, lighting, and fragmentation. Badgers, protected under the Protection of Badgers Act 1992, have established setts along the eastern boundary, risking unlawful disturbance. Pits Wood also functions as an ecological buffer and green corridor. The scheme would overwhelm village and conflicts with planning policy.

I am writing to strongly object to the proposed development of 300 homes in Copford. This is not just about houses it’s about the future of our community, our environment, and the childhoods being shaped here. Copford is a unique and cherished place. It’s not just home to those of us who live here people come from far and wide to enjoy its beauty, its peace, and its wildlife. The walks here are outstanding. Copford is one of the few villages where you can walk a complete circular route around the village without encountering dangerous, busy roads. This is rare and precious, and it makes Copford a haven for families, dog walkers, and nature lovers. My son is only four years old. He loves walking through Pitts Wood, listening to birdsong, and spotting deer and foxes among the trees. He delights in watching tractors and combine harvesters at work in the fields, learning where our food comes from. These experiences are priceless they connect him to nature, to the land, and to the rhythms of rural life. If this development goes ahead, what will be left for him? Concrete, traffic, and overcrowding. Why should we lose this? Schooling: Our tiny village school is already oversubscribed. Adding hundreds of homes will leave local children without places, forcing families to travel miles for education.
Healthcare: It’s already a struggle to get a GP appointment or find a dentist. This development will make an impossible situation worse.
Traffic: The roads through our village are congested and dangerous. Hundreds more cars will turn this into a daily gridlock.
Farmland Loss: This is quality farmland that grows food. Once it’s gone, it’s gone forever. At a time when food security matters more than ever, this is a reckless choice.
Wildlife Habitats: The proposed site is home to badgers, nightingales, deer, red kites, foxes, newts, and countless birds. These habitats are irreplaceable. Destroying them is an irreversible act.
Water and Sewage: Current systems are already stretched. Adding 300 homes risks overwhelming essential services. This development is not proportionate to the size of our village. It will fundamentally change its character, turning a close-knit rural community into an urban sprawl without the infrastructure to support it. Copford is a very special village one that so many people come to enjoy. It is more than a location; it is a way of life. It’s fresh air, open fields, and wildlife. It’s childhood memories being made. Please, do not take this away from us. Reject this proposal or drastically reduce its scale to something sustainable and respectful of our community and environment. It seems to me like Essex- because of its closeness to London, is never protected and this is just not fair.

The preferred option is defensible. The late alternative using the whole field is not.
The Preferred option will:
Maintain the central Wheatfield and contribution to food security with rural separation from Hall Road as required by NDP Policy CE1
Protect landscape and key view
Protect Pitts Wood with buffer zone, including proven badger foraging and wildlife corridors.
Maintain a village hall
Ensure safe access point on School Road and pedestrian route to primary school

NDP transport policy CE5 must be integral, favouring safe cycling/walking, while deterring short-cuts/excessive speed
High quality design should take account of NDP/Aecom requirements of Policy CE3

I am convinced that the proposal for 300 homes East of School Road will be detrimental to the area, and therefore, it should not be approved.
1. It will generate significant extra traffic, bringing heavy congestion on School and London Road, which are already under massive strain. Road safety is a major concern.
2. The new population will put too much pressure on existing local infrastructure, such as schools, doctors' surgeries, dentists, shops, and public transport, which are already struggling to cope.
3. Development will outpace the capacity of local drainage system, sewage treatment and water supply, which are currently at a breaking point.
4. It will bring an adverse impact on natural habitats and biodiversity in the area, damaging protected wildlife and harming rare species, e.g. Nesting sites for Nightingales in the surrounding Pits Wood.

I wish to comment about Policy PP17 (Marks Tey)and PP29 (Copford).
School Road Copford :-
School Road traffic at school times is congested, exacerbated by the rat run from Tiptree Road to London Road.300 houses means up to 600 extra cars.Trying to exit to the London Road is difficult now.
London Road,towards Stane Park traffic at times is at a standstill.
It already takes 30minutes or more just to exit Stane Park at times
Part of the Marks Tey development is in Copford which means an extra 600 homes which pours even more traffic onto the already congested A120 and the A12.
Now the government has scrapped the road improvements to the A120 and A12 together with the new access roundabout I don't see that the existing roads can cope.
The local sewage works is at capacity now.As is water supply.
This development is on farmland and adjacent to Pitts Wood which has nesting sites for rare species.
The number of homes proposed doubles the size of our village.
Are there other sites within the area that could accommodate some or all of the homes.
Public transport is limited to two buses an hour which run close together.
Regardless of what the Government think very few people will cycle to work
Marks Tey Station car parks are already at capacity and we have given up trying to travel anywhere by rail as we cannot park and from Church Road its to far to walk (now in our 80's).
Doctors,Dentists and Colchester Hospital cannot cope now with all the previous development.
Lexden,Stanway,Copford and Marks Tey villages are losing there identities and becoming one large sprawl.
There is no local support for developments of this size.
There is no way the local infrastructure can cope with the total number of homes (2,800,two sites in Marks Tey and Copford in total).
Copford School is nearly at capacity now.

I am writing to formally object to the proposed Local Plan being considered for the above two sites.

I would like to think that the infrastructure will be put into place before these plans go any further.

At 82 years old and as a resident of Church Road Copford Colchester I am deeply concerned that the existing infrastructure is already failing and cannot support further development;
Our nearest bus route is well over one mile away.

My concerns for these sites are:-

Transport and Access

I live over one mile from the nearest bus route, making me dependent on my car.
However,local traffic conditions are becoming dangerous, On school Road the volume of traffic is so high that that vehicles are frequently driven onto the pavements

The Copford School is full now and if we have to go to our nearest shop for groceries we have to avoid the school times.
The volume of cars parked along School Road at these times is ridiculous.Cars are being driven along the pavements to get past, posing a direct threat to pedestrians

Strategic Infrastructure (Rail and Parking)

To attend vital medical appointments at UCLH in London, I rely on Marks tey Station. Recently the car park has been consistently full due to the number of cars causing us to miss trains. .Adding more residents without station parking
will make essential travel impossible for elderly residents,

Education and services

Copford school is currently at full capacity. The village lacks the basic retail infrastructure to support more home, travelling for groceries involves navigating the hazardous traffic conditions mentioned above.

Utilities and Healthcare.

Sewage. The sewage works at Hall Road are already at capacity and cannot sustain additional load.

Healthcare. Local G P surgeries, Dentists and Hospice are already over stretched, furthermore the local hospital is operating under extreme pressure with significant bed shortages. Adding hundreds of new residents will exacerbate this healthcare crisis.

I believe that significant infrastructure improvements _
specifically regarding road safety, sewage capacity and healthcare access - must be fully funded and completed before any further development is considered in this area.

I wish to object to the proposed local plan being considered for the above site.
School Road Copford traffic has increased since we moved here in 2004. At School times School Road is congested. The School is full to capacity.
I understand In 2000 there was a flood opposite the village hall which is why an inlet was created to stop the flooding going into homes, with the number of homes proposed, where are the cars, possibly 600, going to exit and enter the development?
Doctors: It is difficult to get an appointment now, you need the infrastructure to cope with this number of homes.
Marks Tey Station cannot cope now with parking so where will the extra commuters park?
Water supply: The local sewage works is at capacity now, as is water supply.
With the number of homes proposed will double the size of this Parish and will not be able to cope.

As a local resident who has lived on School Road since 2008, I would like to highlight several practical considerations. Safety of local children could be compromised by a busy access point to a sizeable new estate located near the village hall (many parents park here to walk their children to the local primary school). Sewage treatment plant capacity is among infrastructure constraints to consider. Finally, as Pits Wood is such a vital resource , please consider carefully what is a reasonable buffer and, ultimately, what is an appropriate scale for any development in this close-knit rural community.

I wish to object to the proposed inclusion of land to the east of School Road, Copford.

At a recent public meeting, Wellbeck Land Management laid out their proposals for the site which they envisage will contain 300 dwellings.

As part of this, they have ruled out access from both Ashwin Avenue and Hall Road as both are considered to not be suitable for access.
The access would be via a new junction on School Road. The location of this junction would be at the bottom of a steep hill on a blind bend with zero visibility.
This will inevitably lead to many accidents.

The site itself slopes towards the bottom of a natural valley which already suffered from flooding during torrential rain storms.
Covering the site in concrete for roads, paths and buildings will significantly reduce the ability of the land to absorb rain water ant, in turn, will increase the risk of the current flood protection works being overwhelmed leading, in turn, to the potential for flooding of at least 4 properties currently protected by the flood prevention now in place.

I wish to object to the above proposed 300 houses from being built in the field opposite 70 School Road for the following safety reasons:

The field is at the top of the valley leading down to the road which almost forms a basin, in the currant situation the road floods in heavy rain where the entrance would be on School Road without building over arable farmland. You may be aware that a number of years ago the course of School road opposite the field was altered and capped,this was to try to stop the bungalows opposite from flooding, in fact the fire brigade were called one Christmas to pump the gardens out. one bungalow was knocked down as it was empty at the time and so badly damaged the replacement house had to have piling foundations. The other bungalow could not be lived in for about 6/9 months to to allow it to dry out so the residents had to live in a caravan on the drive as they could not find homes for their dogs. It really concerns us what damage will be done to existing properties and where the surface water will drain to on this proposed site if the estate road network and pavements along with the proposed 300 houses go ahead.
School road traffic can be horrendous as it is used by the residents, a rat run for cars and and just recently large lorries and the school traffic, I don't believe that adding what could be 600 more vehicles from this new proposed estate and possibly up to another 1000 from the other proposed site will just be absorbed, because as it is if there is a breakdown, bad weather or accident on the A12 or A120 the traffic queues past my bungalow, as the vehicles cannot get on to the the over capacity London Road. I don't think that I even have to describe the traffic problems since Sainsbury’s and Stane Park shops and warehouses have been built and are still building there and the Tollgate retail estate on the opposite side of the London road roundabout.
To summarise, the local infrastructure is not fit for purpose as it is, without additional major infrastructure investment as Copford village has been overlooked for decades and desperately needs doctors and dentist surgeries, updating of sewage treatment works and additional mains water supplies, an up-to-date surface water system rather than streams that connect to the ROMAN RIVER, new pavements and most importantly new cycle paths to encourage the children and adults to at least cycle to the local school and Marks Tey shops without taking their lives in their hands this is needed now and is without the proposed additional houses.

Development not 'proportionate to the size of the villages' (Vision for Copford with Easthorpe Nplan)
Land identified as areas for building is not fully owned by the landowner/developer
Buffer zone around Pits Wood inadequate-Woodland Trust experts state 50-100m buffer needed given nesting nightingales.
Copford WRC has 33% capacity only remaining, insufficient for 300 homes and additional 1500 PP29
Likely access/egress to site inadequate as onto already congested School Road high risk to young children-and beyond to B1408/A120/A12
No additional connectivity to other areas, no public transport
Does not conform with Parish commissioned Housing Needs Survey.
No additional NHS provision

I am concerned that this is over development of the area.

I object to the proposed development as being too large and unsustainable. The current infrastructure in terms of roads, schooling, medical facilities and waste disposal is already stretched and in many cases inadequate. The proposed development would significantly add to current problems and would also adversely affect the character of the village and surrounding area.
Improvements to the A12 and A120 have already been shelved and following recent new housing developments the traffic on School Road, Copford and London Road through Copford and Stanway is already a mayor problem.

Limit 50 maximum housing units built in Marks Tey & Copford area.
Why: -
Infrastructure can't cope, roads, schools, dentists, water, etc
Poor vehicle movement planning in the area causes movement difficulties, especially at weekends.
Poor infrastructure for moving on foot, by bicycle, etc
Planning for industrial units, NOT built, due to poor demand.
If completed, it adds a large movement of lorries, vans and cars.
Most property occupiers don’t live close to their work
Incompatible area for social housing.
Farmers are paid to save the countryside, Sustainable Farming Incentive, Countryside Stewardship, while councils destroy it with high-density housing developments.

Copford would loose its village character

School Road is a narrow and winding road which is impassable during school drop off and pick up. Adding 600 cars and more to this route will make it unsustainable.

The proposed area is a tranquil rural space which should be retained as an asset not over run by traffic, pollution and noise.

Accessing any jobs locally by foot is just not going to happen, public transport exists but is sparse; crossing school road or London road is already scary now, but with another 600+ cars it will become lethal.

Including the Preferred Options Local Plan Consultation Draft and Policies Map
The Woodland Trust welcomes the opportunity to comment on the Colchester Local Plan Preferred Options. As the UK’s leading woodland conservation charity, our mission is to protect and restore ancient woodland, increase native tree cover, and ensure that planning policy contributes meaningfully to nature recovery, climate resilience, and healthier places for people.
We commend Colchester City Council for producing a Local Plan that places strong emphasis on the environment, green networks, and biodiversity, and for aligning the Plan with the ambitions of the Environment Act 2021 and the Essex Local Nature Recovery Strategy (LNRS). However, we consider that several aspects of the Plan require strengthening to ensure it is sound, consistent with national policy, and capable of effective delivery.
This response sets out our strategic comments on the Plan as a whole, followed by specific objections to Policy PP29 – Land East of School Road, Copford, as shown on the Preferred Options Policies Map.
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1. Vision and Strategic Approach
We support the overarching vision of the Plan to address the climate and ecological emergencies, enhance green networks, and embed health and wellbeing throughout plan-making. The recognition that Colchester is one of the most nature-depleted parts of the country, and that nature recovery must be central to future growth, is welcome.
However, the effectiveness of this vision depends on policy consistency and implementation, particularly where growth pressures intersect with irreplaceable habitats. Allocations that undermine ancient woodland protection risk weakening the Plan’s environmental credibility and internal coherence.
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2. Strategic Policy ST2 – Environment and the Green Network and Waterways
Policy ST2 sets a strong strategic framework for nature recovery, ecological connectivity, and delivery of the Essex LNRS. We strongly support:
• The identification of strategic biodiversity areas
• The emphasis on habitat connectivity and multifunctional green infrastructure
• The requirement for Green Network and Waterways Plans for major development
However, we are concerned that Policy PP29 directly conflicts with the intent of ST2, by allocating development in immediate proximity to an Ancient Semi-Natural Woodland (ASNW) that forms part of the wider ecological network. Development of the scale proposed risks fragmenting, rather than strengthening, the biodiversity network, contrary to the stated objectives of the Plan.
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3. Policy EN4 – Irreplaceable Habitats
We strongly support the inclusion of a dedicated policy on irreplaceable habitats and the recognition of ancient woodland as such. However, for the Plan to be sound, policy wording and allocations must align.
National policy is clear that:
Development resulting in the loss or deterioration of irreplaceable habitats, such as ancient woodland, should be refused unless there are wholly exceptional reasons.
We emphasise that deterioration includes indirect and cumulative impacts, not solely direct land take. Allocations that place high-density residential development adjacent to ancient woodland must therefore be scrutinised against this test at plan-making stage, not deferred to development management.
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4. Policy EN5 – New and Existing Trees & Policy GN4 – Tree Canopy Cover
We welcome the Council’s ambition to increase tree canopy cover and protect existing trees. However, ancient woodland is not simply a collection of trees; it is a complex, irreplaceable ecosystem dependent on long-term stability of soils, microclimate, and hydrology.
Tree planting, canopy targets, or Biodiversity Net Gain cannot compensate for harm to ancient woodland, and policies should make this explicit to avoid misinterpretation at application stage.
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5. Biodiversity Net Gain and Nature Recovery
We support Policy EN2 and the ambition to deliver Biodiversity Net Gain. However, we reiterate that:
• Ancient woodland and its buffer zones must be excluded from BNG calculations
• BNG must not be relied upon to justify allocations that cause deterioration of irreplaceable habitats
This is particularly relevant to Policy PP29.
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6. Place Policy PP29 – Land East of School Road, Copford
Formal Objection
The Woodland Trust objects to Policy PP29 as currently drafted and shown on the Preferred Options Policies Map.
a) Impact on Pits Wood ASNW and Local Wildlife Site
Pits Wood is an Ancient Semi-Natural Woodland and a Local Wildlife Site, and therefore an irreplaceable habitat of the highest sensitivity. The allocation of approximately 300 dwellings immediately adjacent to its southern and eastern boundaries presents a clear risk of deterioration, including:
• Increased recreational pressure from an estimated 700 new residents
• Trampling, soil compaction, and damage to ancient woodland indicator species such as bluebell and wood anemone
• Light, noise, and air pollution
• Domestic pet disturbance
• Increased risk of invasive non-native species
• Long-term degradation of woodland soils and edge habitat
These impacts are well-evidenced, predictable, and difficult to mitigate once established.
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b) Inadequate Buffering
While Policy PP29 acknowledges the need for buffering, it fails to secure a defined, policy-compliant buffer of sufficient width. Best practice, supported by the Woodland Trust, indicates:
• A minimum 50 metre buffer between ancient woodland and development
• Larger buffers (up to 100 metres) where development is of significant scale or intensity
Given the scale of this allocation, we do not consider that the policy provides sufficient certainty that unacceptable edge effects can be avoided.
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c) Conflict with Strategic Biodiversity Priorities
National datasets identify this area as forming part of the Woodland Priority Habitat Network (England) with High Spatial Priority. Such areas are intended to:
• Buffer and expand existing woodland
• Improve habitat connectivity
• Deliver nature recovery at scale
Allocating high-density housing in this location fundamentally conflicts with these objectives and undermines the Plan’s alignment with the Essex LNRS and Policy ST2.
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d) Soundness Concerns
In its current form, Policy PP29 raises concerns in relation to the tests of soundness, in particular:
• Positively Prepared – by failing to avoid foreseeable harm to irreplaceable habitats
• Justified – by selecting a site with clear environmental constraints where less sensitive alternatives may exist
• Consistent with National Policy – given the NPPF’s strong protection for ancient woodland
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7. Recommendations
To address these issues, the Woodland Trust recommends that the Council:
1. Removes or significantly revises Policy PP29 to avoid development that would result in deterioration of Pits Wood ASNW; or
2. Substantially reduces the scale of development and secures:
o A minimum 50–100 metre semi-natural buffer, excluded from private gardens
o Explicit policy wording reflecting NPPF protections for irreplaceable habitats
o Long-term management and monitoring arrangements in perpetuity
Without these changes, we consider that Policy PP29 risks causing irreversible harm and undermining the environmental integrity of the Local Plan.
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8. Conclusion
The Woodland Trust supports Colchester City Council’s ambition to deliver a Local Plan that responds to the climate and ecological emergencies. However, this ambition must be reflected consistently across both strategic policies and site allocations.
Ancient woodland is irreplaceable. Once degraded, it cannot be recreated elsewhere. The precautionary principle must therefore apply at plan-making stage.
We would welcome ongoing engagement with the Council to help identify alternative approaches that meet housing needs while safeguarding Colchester’s most valuable natural assets.

Several equestrian interests in the Copford, Marks Tey and Easthorpe area. Restricted Byway 24 Copford, Restricted Byway 42 Birch, Bridleway 28 Copford and Restricted Byway 43 Birch are all in close proximity and riding/driving distance. Any additional infrastructure in this area must increase accessibility to the network and be at least of bridleway status to not exclude horses from any new infrastructure that will ultimately increase traffic on the roads and the business of other PRoW with users. A restricted byway offers the best accessibility, including access for pedestrians, horse riders, cyclists, and users of non-motorised vehicles (e.g., carriages).

Traffic in School Road is unbearable at times let alone traffic getting out of Allendale Road, getting onto London Road. No local jobs therefore more cars!!
Will infrastructure be put in place re GPs, dentists, schools (which are full up already)
is there sufficient water supply and can local sewage treatment cope?
The farmland has been used for many many years therefore will be an irreplaceable area occupied by
nesting sites in the Wood
Is the design in keeping with the area, namely family homes/bungalows
We do not need more houses in Copford let alone houses in Mark Tey

The Road infrastructure will not support the addional estimated 400 vehicles that this proposal will bring to an already busy local road. The sewerage plant is already at full capacity which is supported by the need of relatively new developments requiring stand along water treatment plants. The primary school is already at full capacity and will not support further entrants.

London road is already at capacity with cars queuing throughout the day, not only at rush hour, additional houses will only exacerbate this issue. The decision to not widen the A120 and A12 will put additional strain on London road if there are any issues with the main arterial roads, which then increases the risk to pedestrians as it is not only local traffic utilising the roads, but those vehicles normally only found on the arterial roads.

There is no additional capacity at local GP surgeries and Colchester general is consistently over capacity and unable to accept more patients. As an operational manager for the East of England Ambulance service I routinely witness a patient demand that is currently unable to be met, more houses are certainly not going to help this.

London road is already at capacity with cars queuing throughout the day, not only at rush hour, additional houses will only exacerbate this issue. The decision to not widen the A120 and A12 will put additional strain on London road if there are any issues with the main arterial roads, which then increases the risk to pedestrians as it is not only local traffic utilising the roads, but those vehicles normally only found on the arterial roads.

There is no additional capacity at local GP surgeries and Colchester general is consistently over capacity and unable to accept more patients. As an operational manager for the East of England Ambulance service I routinely witness a patient demand that is currently unable to be met, more houses are certainly not going to help this.

I strongly object to the proposed 300-house development in Copford. Following the cancellation of the A12 and A120 upgrades, School Road and London Road lack the capacity for 600+ additional vehicles, which will result in total gridlock. Marks Tey Station already suffers from a lack of parking for commuters, and vital services—including GP surgeries, dentists, and schools—are at breaking point. Furthermore, this development presents an unacceptable environmental threat to Pitts Woods and the rural character of Copford Green. Without major infrastructure improvements, sewage capacity, and water supply guarantees, this scale of development is entirely unsustainable.

I strongly object to the 300-house development in Copford. Combined with the 600 proposed for Marks Tey, this totals 900+ homes, which more than doubles the parish size.
With the A12/A120 upgrades cancelled, adding 1,800+ vehicles will cause total gridlock on School and London Road. Furthermore, I have serious concerns regarding sewage capacity and water supply. Crucially, this development threatens Pitts Woods, an irreplaceable habitat for nesting nightingales. This scale of growth is entirely unsustainable and will destroy the rural character of Copford without major infrastructure improvements.

1. Introduction

This representation objects to Policy PP29 – Land East of School Road, Copford on the grounds that it is:
• In direct conflict with the Copford & Easthorpe Neighbourhood Plan (adopted 2023);
• Internally incoherent and undeliverable based on its own policy requirements;
• Contrary to the Local Plan evidence base on infrastructure, environment, and settlement hierarchy;
• Unsound under the adopted National Planning Policy Framework (NPPF, December 2024); and
• Not rendered sound by the emerging draft NPPF (December 2025), which in fact reinforces the same conclusions.

Accordingly, PP29 fails the tests of soundness set out in national policy and should be removed prior to Regulation 19.

2. Fundamental Conflict with the Copford & Easthorpe Neighbourhood Plan (2023)

The Copford & Easthorpe Neighbourhood Plan (“the NP”) was adopted in 2023 and therefore:
• Is less than five years old;
• Forms part of the statutory development plan;
• Carries full weight.

Relevant NPPF provisions (2024)

NPPF paragraph 12 states:
“Where a planning application conflicts with an up-to-date development plan (including neighbourhood plans), permission should not usually be granted.”

NPPF paragraph 14 states:
“Where a neighbourhood plan has been brought into force less than five years before the date on which the decision is made, and the neighbourhood plan contains policies and allocations to meet its identified housing requirement, the adverse impact of allowing development that conflicts with the neighbourhood plan is likely to significantly and demonstrably outweigh the benefits.”

NPPF paragraph 30 states:
“Once a neighbourhood plan has been brought into force, the policies it contains take precedence over existing non-strategic policies in a local plan covering the neighbourhood area.”

Direct conflicts with the Neighbourhood Plan

PP29 directly conflicts with multiple adopted NP policies, including:
• NP Policy H1 (Scale and Form of Development)
The NP restricts development to small-scale, proportionate growth appropriate to Copford’s size and role.
A 300-dwelling allocation represents a population increase of approximately 40–70%, which is manifestly disproportionate.
• NP Policy LS1 (Settlement Separation and Rural Setting)
The NP seeks to prevent coalescence between Copford, Copford Green, Easthorpe and neighbouring parishes.
PP29 materially erodes this separation.
• NP Policy ENV1 (Landscape, Character and Views)
The scale and intensity implied by PP29 cannot be reconciled with protection of rural approaches, landscape character, and the setting of adjacent woodland

As a non-strategic allocation, PP29 cannot override the NP. Under NPPF paragraphs 12, 14 and 30, this conflict alone renders the allocation unsound.

3. Internal Incoherence and Undeliverability of PP29

3.1 Lack of Land Control and Site Assembly
PP29 requires:
• A comprehensive masterplan across the allocation;
• Demolition and replacement of the existing village hall;
• Reconfiguration of the dog park.
However, the Parish Council owns or controls the land containing the village hall, playground and dog park, and there is no agreement to release this land.

Relevant NPPF provisions (2024)

NPPF paragraph 122 states:
“Strategic policies should be realistic and deliverable, and should include clear expectations for delivery of infrastructure.”

NPPF paragraph 35 requires that plans be:
“Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters.”

Without land control, the site cannot be assembled, and the masterplan cannot be delivered. PP29 therefore fails the deliverability test.

3.2 Mutually Incompatible Policy Requirements
PP29 simultaneously requires:
• Approximately 300 dwellings;
• A replacement village hall;
• A local centre;
• Strategic open space and green infrastructure;
• Substantial woodland buffers;
• Biodiversity Net Gain areas;
• Sustainable drainage systems;
• Multiple vehicular and pedestrian access points.

Taken together, these requirements are spatially incompatible on a constrained site adjoining sensitive woodland. Either the housing quantum is unrealistic, or the environmental and community protections are illusory.

Relevant NPPF provision (2024)

NPPF paragraph 15 states:
“Policies should be clearly written and unambiguous, so it is evident how a decision maker should react to development proposals.”

PP29’s internal contradictions mean it is neither clear nor realistic.

4. Infrastructure and Environmental Constraints

The Local Plan evidence base identifies unresolved constraints relating to:
• Wastewater treatment capacity serving Copford;
• Highway capacity along the London Road corridor;
• Primary school capacity;
• Proximity to Ancient Woodland and Priority Habitat at Pits Wood.

Relevant NPPF provisions (2024)

NPPF paragraph 110 requires that:
“Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.”

NPPF paragraph 122 (quoted above) requires infrastructure to be deliverable.

NPPF paragraph 193 states:
“Great weight should be given to conserving and enhancing landscape and scenic beauty.”

NPPF paragraph 199 states:
“Development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland) should be refused, unless there are wholly exceptional reasons.”

Given the scale of PP29, deterioration through recreational pressure and edge effects cannot be avoided. No “wholly exceptional” justification exists.

5. Rural Proportionality and Settlement Hierarchy

Copford is identified as a small rural village with limited services.

Relevant NPPF provisions (2024)
NPPF paragraph 82 states:
“Planning policies and decisions should recognise that sites to meet local housing needs in rural areas may be located adjacent to or beyond existing settlements, provided they are sensitively located and designed.”

NPPF paragraph 84 states:
“Housing in rural areas should be located where it will enhance or maintain the vitality of rural communities.”

A 300-home allocation does not represent sensitive or proportionate growth and would fundamentally alter the character and function of the village.

6. Failure of the Tests of Soundness (NPPF 35)

Under NPPF paragraph 35, plans must be:
• Positively prepared – PP29 conflicts with the NP and Copford’s defined role;
• Justified – no evidence demonstrates why Copford should absorb growth of this scale;
• Effective – land ownership, infrastructure and spatial constraints make PP29 undeliverable;
• Consistent with national policy – PP29 conflicts with paragraphs 12, 14, 30, 82, 84, 122, 193 and 199.

PP29 fails all four tests.

7. Draft December 2025 NPPF Confirmatory Effect

It is acknowledged that the Local Plan will almost certainly be examined against the adopted 2024 NPPF. However, it is notable that the draft December 2025 NPPF reinforces rather than undermines the above conclusions.
In particular, the draft strengthens emphasis on:
• Plan-led and community-backed development, reinforcing neighbourhood plan primacy;
• Avoidance of aspirational or undeliverable allocations;
• Internal policy coherence and spatial realism;
• Proportionate growth in rural settlements;
• Continued protection of irreplaceable habitats;
• Infrastructure realism.

Accordingly, even if PP29 were assessed against the draft 2025 framework, it would remain unsound.

8. Requested Modification

For the reasons set out above, Policy PP29 should be removed from the Local Plan prior to Regulation 19.
At minimum, the scale of development would need to be radically reduced to align with the Neighbourhood Plan, though such reduction would call into question the rationale for the allocation entirely.

Alternatively a more appropriate site for development within Copford, would be the land currently hosting the car boot sale on London Road, a site that was offered up in the councils call for sites under Site ID: 10746.

9. Conclusion

PP29 is unsound, undeliverable, and incompatible with both adopted and emerging national policy. Retaining it risks weakening the Local Plan at examination and undermining confidence in the plan-led system.
It should not proceed.

1) adverse impact on Ancient woodland, policy requires a buffer and onsite biodiversity net gain, this may be insufficient to prevent recreational pressure, causing root damage, disruption off habitats of nightingales, crested Newts, small mammals etc
2)
Inadequate infrastructure especially wastewater. treatment plant is already over capacity with historical contamination issues, 300 homes would exacerbate overload
No capacity at copford school!
3) overdevelopment approximately 2,800 new houses in close proximity
4) Access via school Road would increase congestion of safety of the Children on a already on a dangerous road.
5) loss off rural character.